Bisphenol-A (BPA) is a chemical that was discovered to act like estrogen, a hormone, in the 1930's. Chemists began to use it to make polycarbonate materials and soon afterwards companies began to use it in making plastic products and resins. The plastic industries now make billions of dollars from this one chemical, with a yearly production of 2.5 billion pounds (McGowan, n.d.).This profitable chemical has been very useful in the manufacturing of many items that are used by today's consumer. A person has contact with it through microwavable containers, electronic equipment, eye glass lenses, dental sealants, reusable drink containers, children's toys, epoxy lining of food and drink cans, and all polycarbonate plastic items, including many baby bottles (Gibson, 2007). With all of these wonderful uses in society, why should one be concerned that the Center for Disease Control (CDC) has found BPA in 95% of people who have been tested (Gibson, 2007)? The government agencies that regulate chemical use surely would not allow a dangerous chemical to harm the members of its society after all these years of use. Evidence suggests otherwise, and the levels of BPA found in humans are greater then what has been proven harmful to lab animals, and this stirs up a lot of ethical questions that need to be answered, but don't be fooled (Public Interest Research group, 2007).
Independent scientists have been publishing the results of research that shows the harmful effects of very low exposures to BPA since 1997 (McGowan, n.d.). BPA has been shown to be a hormone disrupting developmental, neural, and reproductive toxicant (Public Interest Research Group, 2007). Researchers have voiced their concerns, for a long time now, because the harmful effects of BPA seen in laboratory studies are very similar to the same types of health issues that are increasing in humans (Hileman, 2007). Cancer, impaired immune function, early onset of puberty, obesity, diabetes, and hyperactivity are just a few samples of the effects of low dose exposure to BPA found by scientists (Gibson, 2007).
A recent report by the Environmental California Research and Policy Center proclaims that five major brands of baby bottles, Avent, Dr. Brown's, Evenflo, Gerber, and Playtex, all leach BPA at levels above what is known to cause harm in lab testing (Public Interest Research Group, 2007). There is a growing concern for young children as their detoxification mechanisms are not fully developed to handle toxic levels of chemicals; along with the fact that they are exposed in the womb, as BPA is known to cross the placenta into the fetus and may cause problems during critical stages of development (Gibson, 2007). Gibson states that the low dose effects of hormone mimicking chemicals have not been accounted for in standard toxicology testing and that due to this, the government may not be protecting society as it should (Gibson, 2007).
Why hasn't the EPA taken steps to investigate this matter? Charles Auer, who heads the toxic chemical division of the EPA, states that they take action when they are allowed to by law (Watson, 2007). In 1976 Congress passed the Toxic Substances Control Act (TSCA) and this allowed existing chemicals to remain in use without any testing. The view of the government is that chemicals "are innocent until proved harmful" (Gibson, 2007). State Representative Jon Hinck believes that the federal law that regulates chemicals has "terrible loopholes," but the EPA stands strongly, believing that there is not enough evidence to ban BPA (Watson, 2007).
In addition to this, the EPA was supposed to implement a program, ordered by Congress in relation to the Food Quality Protection Act of 1996, by no later than 1999, in order to test possible hormone interfering chemicals. This has still not been completed (Ambrose, 2007).
The EPA finally faced a lawsuit from the National Resources Defense Council. Legislators are speaking up because two laws have been passed to help regulate chemicals in our society over the past 10 years. Yet, the EPA has not tested a single one under these programs (Ambrose, 2007). What would cause them to stall, not carry out their responsibilities to society, and cause enough concern for state and local agencies to try to take control themselves?
As the EPA continues to defend their actions while state and local agencies try to gain control, the chemical industries are speaking out against local control. Steve Russell from the American Chemistry Council believes that the federal government is better qualified for making decisions relating to chemical use and the council he represents is for chemical manufacturers (Watson, 2007). Steve Hentges, who represents the American Plastics Council and the manufacturers of BPA, is quoted saying "The evidence has been examined by governments and scientific bodies worldwide. In every case, the weight of evidence supports the conclusion that bisphenol-A is not a risk to human health…"(Kay, 2005). If this is true, then why have so many independent scientific studies been overlooked by the EPA?
Interestingly, as State Representatives began to speak out, the Bush Administration funded $76 million to the EPA for the program that is now called "The Endocrine Disruptor Screening Program" (EDSP)(Ambrose, 2007). Independent scientists have scrutinized the lab test designs and they have found the program to be inadequate as it allowed the use of lab rats that are known to be insensitive to hormone disrupting chemicals. A reproductive and toxicological geneticist, Jimmy Spearow, states that this action "could legitimize levels of chemicals that could be detrimental to sensitive individuals" (Ambrose, 2007). The EPA believes that the chemical companies should choose the breed of rat to be tested and they do not believe that the chemical companies "would select a strain that serves their own financial interests" (Ambrose, 2007). They appear to be allowing chemical industry influence in the complete study design and they are accepting opinions from those who have financial interest in the results of the tests (Ambrose, 2007).
Along with this, the rat chow chosen is soy based, which is known by scientists to have phytoestrogens that will mask the exposure of hormone type chemicals (Hileman, 2007). The EPA has made no guarantees that prenatal exposure will even be tested, although current research shows this to be essential. The design does not use the appropriate dose needed to gain accurate results (Ambrose, 2007). Fred vom Saal, who has expertise in researching BPA, states that "If your objective is not to find anything, that's the perfect way to do it" in reference to the EDSP (Ambrose, 2007). If research has been done in this manner by the chemical companies, then this could explain the reason for the huge discrepancies between the other government funded and industry experiments in the past (Hileman, 2007).
The recent actions of the EPA may seem unethical, as they are being what many may perceive to be unjust and unfair by allowing the chemical industry to lead the way with this new program after ignoring many of the independent scientists studies. This may very well cause harm, result in more badness over goodness, and violate the Value of Life Principle which should be of the utmost importance in a societies moral system from a humanitarian ethics view point (Thiroux, 2007). However, the immorality goes deeper than the EPA, and although the EPA was negligent and irresponsible in their duties, I feel that the unethical issue lies within the National Institutes of Health (NIH) and may be why the EPA has dismissed many of the independent scientists' findings and has given more focus to the industry instead.
The Center for the Evaluation of Risks to Human Reproduction (CERHP) was created in 1998, within the NIH and part of the National Toxicology Program (NTP) and the National Institutes of Environmental Health Sciences (NIEHS), to assess chemicals and to give reports on which ones should be regulated (Cone, 2007, March; Hileman, 2007). The public has recently been made aware that most of this work is being done by a private consulting company called Sciences International (SI) (Cone & Gellerman, 2007). SI not only has been reviewing literature and writing initial reports, but they are also involved in choosing the scientific panel that determines the outcomes of the use of the chemicals (Hileman, 2007). Although it is normal for an agency to hire private contractors, this is suspicious as the CERHP has given SI an administrative role (Cone & Gellerman, 2007).
Red flags have gone up as the National Toxicology Program is now aware that SI also represents many of the chemical companies, such as DOW and BASF who manufacture BPA, and others who make the chemicals that they have been doing government reviews for over the last decade (Cone & Gellerman, 2007). The CERHP's director states that SI was not required to disclose any financial conflicts of interest (Cole, 2007). The strong role of SI in its involvement with NIH became noticed when the Environmental Working Group reviewed the very industry biased report presented concerning BPA. Fred vom Saal who does BPA research for the NIH states the following about the SI report "It's a combination of inaccurate information and blatant bias as it exists in its draft form. They specifically ignore fatal flaws in industry-sponsored publications" and that SI misrepresented government funded studies and that they also failed to mention that some of the studies were, in fact, industry funded (Cone, 2007).
The Environmental Working Group gained access of a letter written from SI to R.J. Reynolds asking to be allowed to represent them concerning regulation of a pesticide with the EPA (Cone, 2007). The SI company founder stated that SI "serves the private sector, including many trade associations, on a wide range of health and risk assessment issues. However, we are different from most other consulting firms in that we also currently serve government agencies" and this provides "a unique credibility to negotiate with regulators on behalf of our private sector clients" (Cone, 2007).
The investigation of SI is still in its early stages, however from what I have already absorbed from my research, I believe SI and the associating chemical industries to be unethical in all of their actions revolving around the use of BPA. Again, from a Humanitarian ethics view, both have acted dishonestly and have been shown to be untrustworthy to society by hiding, covering up, and inappropriately arranging research data. They have shown themselves to be unjust and unfair by their unequally distribution of goodness- the financial gains that they have both made at the expense of society, the government agencies that want to protect society, and of other concerned researchers. They have used all of us as a means to their end. They have violated the Principle of Goodness by not preventing harm and they have caused badness, not only in the use of harmful chemicals, but by causing society to have a negative opinion about the government agencies that are trying to protect them.
Granted, the harmful effects of BPA can not be specifically tested on humans as that would raise more ethical issues, but the correlation of human disease and current studies can be seen so they violated the Value of Life Principle. I can not justify their rights to individual freedom in conducting research of chemicals that will only profit them and harm society. I guess I can finally agree with Steve Russell on one thing- the federal government is better qualified at making these decisions- that leaves no room for the chemical industry and their "protectors!"
Annotated Bibliography
Ambrose, S.G. (2007, May). Scientists criticize epa chemical screening program. The Dallas Morning News.
Sue Goetrick Ambrose informs us on how the EPA has not performed their responsibilities in implementing an ordered program by Congress in relation to the Food Quality Protection Act of 1996 and hormone interfering chemicals, that was supposed to be in place by 1999. Now the program is finally being developed, under the Bush Administration, following a lawsuit by the National Resources Defense Council. This program, the Endocrine Disrupter Screening Program, has been reviewed by independent scientists who have found many flaws in the research design along with biased participation of the chemical industry. Independent researchers show concern that the design of the research program is not sensitive enough to detect the harmful effects of the chemicals and that results will be favorable for the chemical industry. This will allow the continued use of the chemicals and the continuing of harmful effects on human health.
Cone, M. (2007, March). Public health agency linked to chemical industry. LA Times.
The LA Times staff writer, Marla Cone, informs her readers of the conflicts of interest of the company, Sciences International, in their preparation of reports for the toxicity of chemicals for the National Institute of Health. The biased position of this company was first revealed by the Environmental Working Group after they reviewed reports relative to a chemical called Bisphenol-A. Further investigation reveals questionable actions and communications between the government and industry agencies with Science International.
Cone, M. & Gellerman, B. (2007, March). Living on earth. Retrieved May 19, 2007 From:
http://www.loe.org/shows/segments.htm?programlD=07-P13-00010&segmentlD=2
Bruce Gellerman hosts the LA Times reporter, Marla Cones, on his program, Living on Earth. This is the discussion concerning the conflicts of interest that have been found in the current evaluations of chemical toxicity presented to the government agencies that are suppose to regulate such chemicals in order to prevent harm to the public. Sciences International (SI) is presently under federal contract to collect data and write the first drafts of reports, which are later presented for further review. This same company also represents DOW and NBASF, who are both producers of Bisphenol-A, the current chemical under investigation for determination of harmful health effects. The Environmental Working Group has reviewed a recent draft and they state data has been omitted from studies and that there are inaccuracies. The National Toxicology Program has growing concerns and is investigating whether or not a conflict of interest policy applies to SI.
Gibson, R.L., (2007). Toxic baby bottles-scientific study finds leaching chemicals in clear plastic baby bottles. Retrieved May 18, 2007, from
http://www.uspirg.org/uploads/Fc/FR/FcFROlpqsxJ6IoedOygzSQ/Toxic-Baby-Bottles.Feb2007.pdf
The Environmental California Research and Policy Center is a 501(c)(3) organization whose aim is to protect California air, water, open spaces, and public health. This report shows that Bisphenol-A (BPA) causes health problems as it is a neural, developmental, and reproductive toxicant. Gibson states that BPA exposure is common and that harmful levels have been found in 95% of humans. She explains how children are more at risk, especially with the leaching of this chemical from five popular baby bottles. Gibson addresses the importance of the government needing to take action in regulating the use of toxic chemicals, as the present ways are not sufficient.
Hileman, B. (2007, April). Bisphenol-a on trial. Chemical & Engineering News, 85(16).
This article was written by Bette Hileman and it was posted in the Government & Policy section of Chemical & Engineering News provided by the American Chemical Society. Hileman addresses the issues in discrepancies between government funded and industry research of Bisphenol-A (BPA). The majority of government funded experiments reveal harmful effects of this chemical, while none of the industry studies show any. Hileman shares reasons why these studies may have provided the results that occurred and then she writes about the bias of the company who writes the industry reports. She concludes with the known harmful effects of BPA and its possible relationship to emerging illnesses in humans.
Kay, J. (2005, March). California legislature considers bill to ban chemical from kids' products. San Francisco Chronicle.
Jane Kay, the Chronicle Environmental Writer, informs her readers of the works of Assemblywoman Wilma Chan's bill, AB319, which would prevent the use of Bispheno-A in any products produced for children 3 years of age or younger. This bill would also prohibit phthalates, another harmful chemical, from being used in the same products. Kay presents comments from the American Plastic Council who believes that there is no risk to human health from exposure to these chemicals as they ignore the presented research that claims otherwise.
McGowan, M. (n.d.). Uncovering a hidden danger. Mizzou News. Retrieved May 19, 2007, from the University of Missouri, Columbia,
http://atmizzou.missouri.edu/Jun03/plastics.htm
McGowan informs his readers how researchers from the University of Missouri, vom Saal and Welshons, have continually warned both public and government agencies about the harmful effects of Bisphenol-A (BPA) since 1997. He states that vom Saal said that scientists have been aware, for many years, of the chemical's potential of leaching from products and the harmful health effects that this can produce. vom Saal has been quoted to state that there are other products that can be used that do not have BPA in them and that there is no reason to continue to use such a potentially harmful chemical. vom Saal believes that it is only a matter of time before the government takes action, as evidence is growing to prove the harm caused by BPA.
Public Interest Research Group. (2007, February). Toxic chemical leaches from popular baby bottles. Retrieved May 18, 2007, from
http://www.uspirg.org/newsroom/toy-Safety/toy-safety-news/toxic-chemical-leaches-from-popular-baby-bottles
This article is a news release informing the public of the current results of a scientific study that found a harmful chemical, Bisphenol-A, leaching out of popular baby bottles. This study was performed by the Environmental California Research Group, which revealed that the following baby bottles leach the chemical: Avent, Dr. Brown's, Evenflo, Gerber, and Playtex. The group urges the government to take action and it also makes recommendations for parents who should be concerned for their children's health. The group feels that parents do not have the information that they need to protect their children.
Watson, T. (2007, May). The hazards in our plastic. The Seattle Times.
Tom Watson is a project manager for King County's Recycling and Environmental Services. He writes this article to inform the public on the basic health concerns related to food-related plastics and states that Bisphenol-A is known to cause reproductive problems at very low amounts in animals that have been studied. Watson offers simple tips in order for one to limit exposures that occur daily. In this article he mentions the Institute for Agriculture and Trade Policy's recommendation for one not to use plastic or plastic wrap in the microwave as "microwave safe" only means that the product will hold up to microwaving. As the American Chemistry Council states, it doesn't mean that it is chemically safe. This is a simple article, yet it is filled with resources and information for the average consumer.
Watson, T. (2007, May). States and cities move to curb toxic substances the epa hasn't. USA TODAY.
Traci Watson reports on how states and cities are stepping up to take action against the harmful chemicals that are being allowed in consumer products. State officials claim that the EPA is not acting sufficiently; the EPA feels that they are not justified to ban the chemicals; and the chemical industries feel that the regulation of chemicals should be left to the EPA- not state or local agencies. The Government Accountability office states that the present federal law, the Toxic Substances Control Act of 1976, is not sufficient for the EPA, but the EPA defends their position with the act…and their actions…or lack of action as one is to believe after reading this article.
Other References
Thiroux, J. & Krasemann, K. (2007) Ethics theory and practice (9th ed.). Upper Saddle River, NJ: Pearson Education, Inc.
-Wanda Finney
Wanda Finney is an activist in the MCS community and serves as a member of the Board of Directors for MCS America, while currently pursuing a degree in Environmental Health Ethics. Both Wanda and her son have been doctor-diagnosed with MCS (multiple chemical sensitivity).
Copyrighted © 2007 Wanda Finney
Printed with Permission
